QA2020-118 - FMI - T30.00

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Feb 01, 2024
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QA2020-118

Question


FMI T30.00 - system-type (field c0040) The definition provided for ‘Not applicable’ seems misleading. 2 cases are to be distinguished: intermediaries providing indirect access to FMI, and intermediaries not providing so. An intermediary providing indirect access to FMI provides sub participation to a PS, a CSD or a CCP. That is the case when banks provide sub participation to Target 2, Fedwire…, sub custody to Euroclear, DTCC…, or when clearing brokers are intermediaries to CCP. In this case, FMI are to be declared as PS, CSD or CCP in this field, even if services are not provided by an intermediary that is not an FMI. On the other hand, when payments are provided by a correspondent bank without any knowledge on channels to convey them, Not applicable would be relevant. Is the approach described in the Background in line with SRB guidance?


Response


We agree with the approach proposed by the submitter: 2 cases are to be distinguished: intermediaries providing indirect access to FMI, and intermediaries not providing so. An intermediary providing indirect access to FMI provides sub participation to a PS, a CSD or a CCP. That is the case when banks provide sub participation to Target 2, Fedwire…, sub custody to Euroclear, DTCC…, or when clearing brokers are intermediaries to CCP. In this case, FMI are to be declared as PS, CSD or CCP in this field, even if services are not provided by an intermediary that is not an FMI. On the other hand, when payments are provided by a correspondent bank without any knowledge on channels to convey them, Not applicable would be relevant. This approach is also in line with QA2019-57 available on the SRB website. Please note that, consistently with the said approach, custodian banks submitting an FMIR are still expected to identify their sub-custodians in the report.